Comment submitted by Indiana Department of Environmental Management (IDEM)

Summary: The Indiana Department of Environmental Management (IDEM) supports the proposed rule to revise effluent limitations for unmanaged combustion residual leachate, citing its potential to reduce costs for steam electric power generating facilities. While generally supportive, IDEM recommends removing the requirement for interim best professional judgment (BPJ) limits for certain discharges to avoid administrative burdens and recommends further revisions to prevent burdensome BAT analyses for functional-equivalent discharges.